September 27, 2023

How to scale carbon removal without undermining emission cuts

Our new report outlines 12 solutions to mitigation deterrence

Oversight, transparency and quality assurance are among the principles policymakers need to put in place to minimise the moral hazard of carbon removal, according to our new analysis.

Measures to remove carbon dioxide from the atmosphere are needed alongside rapid and deep greenhouse gas emission cuts to deliver climate targets such as those in the 2015 Paris Agreement. In a word, we need to scale carbon removal and emissions cuts.

But with some governments and companies advocating continued high fossil fuel use well beyond 2050, there are concerns that the mirage of being able to remove sizeable volumes of carbon in future could displace or delay efforts to reduce emissions today.

Our new report, How to avoid carbon removal delaying emissions reductions, provides a 12-step framework for understanding and reducing these ‘mitigation deterrence’ risks.

“Decision makers must balance the risk of exaggerated reliance on future carbon removal against the risk that carbon removal is not deployed enough. Right now, the risks of mitigation deterrence are both unchecked and hindering the deployment of carbon removal. Our report suggests ways to address this situation,” said Dr Sylvain Delerce, Carbon Gap’s Associate Science Director and report co-author.


“The report offers clear guidance on how policymakers, corporations, and climate negotiators can responsibly accelerate carbon removal without it becoming an excuse for climate delay or inaction,” Robert Höglund, co-author of the report.

The Intergovernmental Panel on Climate Change (IPCC) defines three distinct roles of carbon removal:

  • Supporting net zero targets alongside emission reductions
  • Neutralising hard-to-abate emissions at net zero
  • Achieving net negative emissions to reverse temperature overshoot.

For each use case, the report lays out specific policy and accountability recommendations that can both remove factors that encourage mitigation deterrence and create guardrails to limit its impact. These include:

  • Setting separate short and medium-term emission reduction and carbon removal deployment targets
  • Requiring high-quality, permanent carbon removal for neutralising fossil fuel emissions (rather than, for example, seeking to rely on tree-planting)
  • Setting climate targets that recognise the limited availability of carbon removal

“Concern that removals will undermine climate action is grounded but has led to a paralysing and unproductive debate. Let’s make things practical: we can and must design policies that proactively reduce this risk, delivering our dual goals of more ambitious emission cuts and carbon removal scale-up” said Eli Mitchell-Larson, Carbon Gap’s Chief Science and Advocacy Officer and report co-author.

Some jurisdictions including the EU are currently establishing targets, policies and regulations to deliver carbon removal. Carbon Gap advocates that the EU and other jurisdictions develop their frameworks according to the 12 principles outlined in the report.

The full set of 12 recommendations comprises:

  1. Remove obstacles for emissions reductions
  2. Support the development of CDR today
  3. Require like-for-like compensation (permanent storage for fossil carbon, biological storage for biogenic carbon)
  4. Regulate climate-related claims by companies and other entities to prevent ‘greenwash’
  5. Set separate fixed targets for emissions reductions and CDR in the short and medium terms
  6. Set short-term emissions reductions targets, based on remaining carbon budgets, on top of long-term net zero targets
  7. Only plan for a limited amount of removals to be available for meeting net zero targets (the IPCC’s first use case)
  8. Establish principles for when it is appropriate to use carbon removal instead of emissions reductions
  9. Set and implement targets that avoid or minimise temperature overshoot
  10. Demand transparent and accessible CDR plans
  11. Allocate future responsibility for CDR to address overshoot
  12. Set targets that include a country’s upstream and downstream emissions